California Delete Act Imposes New Obligations On Data Brokers

On October 10, 2023, Governor Newsom signed into law SB 362, known as the "California Delete Act" or "Delete Act", which had been passed by the legislature at the end of the 2023 legislative session on September 14. The Delete Act amends California's existing Data Broker Registration law (Cal. Civ. Code Section 1798.99.80 et. seq). Among other things, the law imposes additional registration requirements on top of those that already exist, doubles the administrative fine for failure to register, requires the California Privacy Protection Agency (CPPA) to set up a one-stop shop deletion mechanism that allows consumers to make requests to all registered data brokers, and obligates data brokers to access the mechanism every 45 days and process each and every deletion request made by consumers within a prescribed timeframe (including directing all service providers and contractors of the request).